Introduction
Grant Legal respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how we look after your personal data when you visit our website (regardless of where you visit it from) and tell you about your privacy rights and how the law protects you.
Purpose of this privacy policy
Grant Legal Services Limited (collectively referred to as “Grant Legal“, “we“, “us” or “our“) is the data controller and is responsible for your personal data.
This privacy policy aims to give you information on how Grant Legal collects and processes your personal data through your use of this website.
It is important that you read this privacy policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and privacy policies and is not intended to override them.
This website is not intended for children and we do not knowingly collect data relating to children.
- Contact Details
Our nominated representative is Tom Grant who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy or our privacy practices, please contact us in the following ways:
Full name of legal entity: Grant Legal Services Limited
Email address: [email protected]
Postal address: Jubilee House, Globe Park, Marlow, Buckinghamshire SL7 1EY
Telephone number: +44 (0)20 3858 0027
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.
- Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include anonymous data where the identity has been removed.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
- Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.
- Contact Data includes billing address, email address and telephone numbers.
- Financial Data includes bank accounts.
- Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
- Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
- Usage Data includes information about how you use our website, products and services.
- Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
Where we need to collect personal data by law, or under the terms of an engagement we have with you, and you fail to provide that data when requested, we may not be able to perform the legal services we have or are trying to enter into with you.
We use different methods to collect data from and about you including through:
- Direct interactions. You may give us your identity, contact and financial data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you instruct us to act on your behalf or when you request details of our services or subscribe to our publications.
- Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies and other similar technologies. Please see our Cookies Notice for further information.
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
- where we need to perform the contract we are about to enter into or have entered into with you.
- where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
- where we need to comply with a legal obligation.
- where you have given us your explicit consent to using your personal data.
Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email. You have the right to withdraw consent to marketing at any time by contacting us.
We have set out below a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so.
Please note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|
Purpose/Activity
|
Type of data
|
Lawful basis for processing including basis of legitimate interest
|
| To register you as a new client | (a) Identity
(b) Contact |
Performance of a contract with you and legal obligation |
|
To process and deliver legal services including: (a) Manage payments, fees and charges (b) Collect and recover fees due to us |
(a) Identity
(b) Contact (c) Financial (d) Transaction (e) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary for our legitimate interests (to recover debts due to us) |
| To manage our relationship with you which will include:
(a) Providing legal advice in accordance with the terms of our engagement with you (b) Notifying you about changes to our terms or privacy policy (c) Asking you to leave a review or take a survey |
(a) Identity (b) Contact (c) Profile (d) Marketing and Communications |
(a) Performance of a contract with you (b) Necessary to comply with a legal obligation (c) Necessary for our legitimate interests |
|
To enable you to complete a survey |
(a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications |
(a)Performance of a contract with you
(b)Necessary for our legitimate interests (to study how clients use our products/services, to develop them and grow our business) |
|
To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data) |
(a) Identity (b) Contact (c) Technical |
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation |
|
To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you |
(a) Identity
(b) Contact (c) Profile (d) Usage (e) Marketing and Communications (f) Technical |
Necessary for our legitimate interests (to study how clients use our services, to develop them, to grow our business and to inform our marketing strategy) |
|
To use data analytics to improve our website, products/services, marketing, client relationships and experiences |
(a) Technical (b) Usage |
Necessary for our legitimate interests (to define types of clients for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy) |
|
To make suggestions and recommendations to you about services that may be of interest to you |
(a) Identity
(b) Contact (c) Technical (d) Usage (e) Profile (f) Marketing and Communications |
Necessary for our legitimate interests (to develop our products/services and grow our business) |
- Marketing
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.
You will receive marketing communications from us if you have requested information from us or purchased services from us and you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
- Opting out
You can ask us or third parties to stop sending you marketing messages at any time by contacting us at any time, using the contact details set out at section 7.
Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of engaging us as your legal adviser.
- Cookies
You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our Cookies Notice.
- Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table above in section 7:
- agents and advisers we use;
- the Gambling Commission of Great Britain and other regulators or licensing authorities;
- companies, organisations and individuals that we introduce you to;
- any party linked with you or your business;
- companies, organisations and individuals that you ask us to share your information with;
- to our bankers to the extent necessary to comply with anti-money laundering and terrorist financing legislation;
- marketing companies who help us manage our electronic communications with you;
- third party organisations that provide IT services to us.
You can find details of how these third parties use your personal information by looking at their privacy policies, all of which should be available on the relevant websites, or on request.
We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.
We will only send your data outside the United Kingdom and the European Economic Area to:
- follow your instructions to us to do so;
- comply with a legal duty;
- work with our agents and advisers who we use to help provide our services to you.
Whenever that occurs we ensure protection is afforded to your personal data by ensuring at least one of the following safeguards is implemented:
- we will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
- where we use certain service providers, we use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
After the decision of the CJEU in the Schrems II case, in which the CJEU found that the US/EU Privacy Shield does not afford sufficient protection for personal data when transferred to the US, we have been monitoring the instances in which personal data is transferred to the US to establish whether any such transfer presents a significant risk to your rights and freedoms even when done under the relevant EU Model Clauses. If it does, we commit to making necessary changes.
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
Please contact us if you require further information about our retention policy using the contact details above.
Under certain circumstances, your personal data rights are:
- your right to be informed if your personal data is being used;
- your right to get copies of the personal data we hold about you;
- your right to get your data corrected;
- your right to get data deleted;
- your right to limit how we use your data;
- your right to get personal data from us in a way that is accessible;
- your right to object to the use of your data;
- your rights relating to decisions being made about you without human involvement; and
- your right to raise a concern.
There are exceptions to these rights, particularly if we are processing your personal data for the purpose of providing legal advice to our clients, your rights may be limited.
If you wish to exercise any of the rights set out above, please contact Tom Grant on the details provided at section 7.
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated. We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
For more details regarding your personal data rights, please visit the ICO’s website: https://ico.org.uk/your-data-matters/
- How to make a complaint
If you have a question about the information provided in this Notice, or you have a concern or complaint about the way in which we process your personal data, please contact our Tom Grant via the details provided at section 2.
In any event you have the right to address a complaint to the Information Commissioner’s Office. The Information Commissioner’s Office can be contacted at:
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF www.ico.org.uk. The ICO helpline number is 0303 123 1113.